Privacy PolicyEffective Date: September 5th, 2017

Your privacy is important to the Confirmit group of companies (“Confirmit”). This policy discloses the information practices for Confirmit web site www.confirmit.com and our mobile applications , including what type of information is gathered and tracked, how the information is used, and with whom the information is shared.

EU – U.S. Privacy Shield

Confirmit, Inc. and its subsidiary Customersat.com (jointly, “Confirmit Inc”) participate in and have certified their compliance with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework.. Confirmit Inc is committed to subjecting all personal data received from European Economic Area (EEA) member countries and and Switzerland Respectively, in reliance on the Privacy Shield Frameworks, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List: https://www.privacyshield.gov/list

Confirmit Inc is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Confirmit Inc complies with the Privacy Shield Principles for all onward transfers of personal data from the EEA and Switzerland,, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Confirmit Inc is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Confirmit Inc may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

PHISHING Emails That Reference Confirmit

We have been informed that e-mails with the subject “Important Information Regarding Your XXXX Account”, or similar, are being sent by parties not affiliated with Confirmit. These emails ask recipients to provide login information related to an account that might be held at the company referenced in the subject line. The emails point to this webpage, Confirmit’s Privacy Policy, for more information.

Confirmit is not responsible for the content of these emails. If you believe that you have been asked to provide personal information, please approach the company with whom you hold the account for more information and instructions. Confirmit does not engage in such practices.

Note that Confirmit, as a provider of online survey software, enables its customers to send emails to individuals asking them to participate in market research surveys, or to provide customer and employee feedback. Confirmit does not authorize, approve, or in any other way bear responsibility for emails sent out by clients under the terms of their contract to license Confirmit.

Two Main Categories of Confirmit Sites

Confirmit runs two main categories of Internet sites:

For the first category, Confirmit acts as a SaaS provider for companies conducting data collection and reporting activities via the Internet. You may be submitting responses to web surveys, and the template of the survey may state "Powered by Confirmit". Web surveys launched by Confirmit Customers may be hosted on Confirmit's SaaS environments, or alternatively they may be hosted on customer's own hosting environment (www-addresses other than Confirmit’s). In any of these cases, please be aware that it is our customers who are initiating or performing the data collection, and it is therefore our customers who instruct Confirmit who to collect data from, and it is our customers who control the use the collected data. Confirmit is acting as a data processor (as defined in the EU Data Protection Directive), whereas our customer is the data controller. For more details about how our customer intends to use your data, please refer to the privacy policy of the Confirmit customer from whom the e-mail and web survey originate. For more information related to our role as a data processor, please see the “Additional Information” section below.

NOTE: For information about cookies when you use our SaaS environment, please refer to our Cookie Policy. We do not use cookies in surveys you are invited to take via an e-mail invitation with a clickable link, or via pop-ups, but the party delivering the survey to you may.

The second category of sites we manage is related to information offered by Confirmit to customers, prospects, and other visitors (the Confirmit website, the Confirmit Extranet, etc).

The remainder of this policy is related to this latter type of sites.

Personal Information

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. In general, you can visit Confirmit on the Internet without telling us who you are and without giving any personal information about yourself. There are times, however, when Confirmit or our partners may need information from you.

You may choose to give us personal information in a variety of situations. For example, you may want to give us information, such as your name and address or e-mail id, zip code, resume, and additional contact information such as your phone number. We intend to let you know how we will use such information before we collect it from you; if you tell us that you do not want us to use this information to make further contact with you beyond fulfilling your requests, we will respect your wishes. If you give us personal information about somebody else, such as a spouse or work colleague, we will assume that you have his or her permission to do so.

Additional Information

In relation to the first category above, Confirmit collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Confirmit’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Confirmit will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Device Information

When you download and use our Services, we automatically collect information on the type of device you use, operating system version, and the device identifier (or "UDID").

The Mobile Apps do not require location permission in order to be used. However, our clients who are using our Mobile Apps in order to collect data from you, may request that the Mobile Apps collect your precise geolocation. Should location be requested, you will be prompted by the operating system of your device with a message that the Mobile App has requested to access the device location. You can accept or reject that. If permission has been granted, this permission can be later changed at any time under the operating system Settings area.

Depending on our Client’s use of the Mobile App, the Mobile App may also use beacons or similar technologies as part of the survey-taking.

Use of Personal Information

In relation to the second category above, the following paragraphs describe in more detail how Confirmit may use your personal information. Depending on the specific Confirmit website you are visiting, one or more of the following may apply.

To fulfill your transaction request;

To provide you with a subscription;

To provide you with support and consulting services;

To verify your identity;

To provide information on products, services or callback requests;

To send you specific marketing materials;

To allow our business partners to contact you for marketing purposes;

In connection with a job application or inquiry;

To contact you about employment consideration; and

To invite you to complete web surveys.

If you no longer wish to receive marketing communications from us, you may opt-out by following the unsubscribe instructions located at the bottom of each communication. If you no longer wish to allow us to share your information with third parties for marketing purposes, you may contact us at privacy@confirmit.com to opt-out. If you wish to opt-out from marketing emails provided by third parties, you must contact that third party directly.

Information for Confirmit Business Partners

If you represent a Confirmit Business Partner, you may visit a Confirmit Web site intended specifically for Confirmit Business Partners. We may use information provided on that site to administer and develop our business relationship with you, the Business Partner you represent, and Confirmit Business Partners generally.

Information for Confirmit Customers

If you work for a Confirmit Customer, you may visit a Confirmit website intended specifically for Confirmit Customers. We may use information provided on that site to administer and develop our business relationship with you, the Customer you work for, and Confirmit Customers generally.

Other Confirmit Web Site Notices

In some cases, specific Confirmit websites may contain other notices about their use and the information practices applicable to those sites.

Our Worldwide Practices

Confirmit is a global organization with legal entities, business processes, management structures, and technical systems that cross borders.

Our privacy practices are designed to provide protection for your personal information, all over the world.

We may share your personal information within Confirmit and transfer it to countries in the world where we do business. Some countries may provide less legal protection for your information. In such countries Confirmit will still handle information in the manner we describe here.

Sharing With Service Providers

We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us.

These services may include:

Sending marketing communications

Fulfilling subscription services

Conducting research and analysis

Passive Collection

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

Tracking Technologies

Confirmit and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, to keep track of the domains from which people visit, we may extract some information about your transactions in a non-identifiable format and combine it with other non-identifiable information such as clickstream data, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. To manage Flash cookies, please click here.

We partner with third parties to display advertising on our website or to manage our advertising on other sites. Our third party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here or if located in the European Union click here. Please note you will continue to receive generic ads.

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

Service Quality Monitoring

Certain Web transactions may also involve your calling us or our calling you. Please be aware that it is Confirmit's general practice to monitor and in some cases record such calls for staff training or quality assurance purposes.

Personalized URL Link

On occasion, we may personalize and customize websites for certain visitors. If you visit one of these sites, you may find it customized with references to products and/or services that we believe may be of interest to you, based on your previous interactions with Confirmit and information you have provided to us. While you are visiting these websites, we may collect information about your visit to better tailor the site to your interests. An invitation to visit one of these websites is usually presented as a personalized URL in an e-mail, a notice on a Web site registration page, or as a response to you logging on to a certain website.

If you choose to visit one of these websites, you are agreeing to let Confirmit collect information about your visits, and also to its association with other information about you and your relationship with Confirmit. If you do not wish your information to be used in this way, do not accept the invitation to visit these sites.

Disclosures Required by Law or to fulfill a Business Transition

We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If Confirmit is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

Links to Non-Confirmit Web Sites

Confirmit websites may contain links to other websites. Confirmit is not responsible for the privacy practices or the content of those other websites.

Notification of Changes

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

User Data Supplementation

We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include:

Purchased marketing data about our customers from third parties that is combined with information we already have about you, to create more tailored advertising and products.

Privacy Questions and Access

If you have any questions about this policy, you can send an email to the Confirmit website coordinator. The address for this is privacy@confirmit.com. You can also contact us at this address, 300 Seventh Ave. 3rd FL New York, NY 10001 if you have a question about Confirmit's handling of your information. Alternatively, you may contact us at the physical addresses of the office closest to you, see our list here. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Upon request, Confirmit will provide you with information about whether we hold any of your personal information. If you wish to obtain a copy of particular information you provided to Confirmit, or if you become aware that the information is incorrect and you would like us to correct it, update it or delete it, contact us at privacy@confirmit.com. We will respond to your access request within a reasonable timeframe. If you are enquiring on behalf of data we collect under the instructions of our customers (see the section labelled “Additional Information” above), we will refer your enquiry to such party.

Before Confirmit is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will endeavor to respond within an appropriate timeframe.

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